In the Matter of the Estate of Arthur E. Brown

153 A.3d 242, 448 N.J. Super. 252, 2017 WL 367992, 2017 N.J. Super. LEXIS 8
CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 26, 2017
DocketA-1086-14T4
StatusPublished
Cited by31 cases

This text of 153 A.3d 242 (In the Matter of the Estate of Arthur E. Brown) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Estate of Arthur E. Brown, 153 A.3d 242, 448 N.J. Super. 252, 2017 WL 367992, 2017 N.J. Super. LEXIS 8 (N.J. Ct. App. 2017).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1086-14T4 APPROVED FOR PUBLICATION

IN THE MATTER OF THE ESTATE January 26, 2017 OF ARTHUR E. BROWN, DECEASED. ______________________________ APPELLATE DIVISION

Argued September 28, 2016 – Decided January 26, 2017

Before Judges Fuentes, Simonelli and Gooden Brown.

On appeal from the Superior Court of New Jersey, Chancery Division, Probate Part, Burlington County, Docket No. 2014-0895.

Stephanie L. DeLuca argued the cause for appellant Estate of Arthur E. Brown (Lenox Law Firm, attorneys; Ms. DeLuca, of counsel and on the briefs).

Jennifer L. Cavin, Deputy Attorney General, argued the cause for respondent New Jersey Department of Human Services (Christopher S. Porrino, Attorney General, attorney; Melissa H. Raksa, Assistant Attorney General, of counsel; Ms. Cavin, on the brief).

The opinion of the court was delivered by

SIMONELLI, J.A.D.

This appeal involves a priority lien that the Division of

Medical Assistance and Health Services (DMAHS) filed against the

Estate of Arthur E. Brown (Estate) pursuant to N.J.S.A. 30:4D-

7.2 for reimbursement of $166,981.25 in Medicaid benefits Arthur E. Brown (Arthur)1 received from July 1, 2008, to the date of his

death on April 14, 2013. DMAHS determined that the lien

attached to all assets in the Estate, including Arthur's one-

third elective share against the augmented estate of his wife,

Mary V. Brown (Mary) that included the proceeds from the sale of

the couple's former marital home.

Thomas M. Brown (Thomas) filed a complaint as next-of-kin,

seeking a judgment discharging the lien pursuant to N.J.S.A.

30:4D-7.8. Thomas alleged that because the elective share

statute, N.J.S.A. 3B:8-1, did not apply to Arthur, the lien

claim should be satisfied from the sole assets remaining in the

Estate, approximately $5000. In the alternative, Thomas alleged

that Arthur's elective share was zero when calculated pursuant

to the elective share statutes.

Thomas appeals from the July 29, 2014 Chancery Division

final judgment, which denied entry of judgment discharging the

lien, and from the September 26, 2014 order, which denied his

motion for reconsideration. Thomas also appeals from the May

22, 2015 order, which established the amount of Arthur's one-

third elective share of Mary's augmented estate. We affirm the

judgment and orders.

1 We use first names to identify the parties for ease of reference. We mean no disrespect in so doing.

2 A-1086-14T4 I.

We begin our analysis with a review of the federal and

state Medicaid statutes and regulations and factual background

relevant to this appeal. Medicaid is a federally-created,

state-implemented program that provides "medical assistance to

the poor at the expense of the public." Estate of DeMartino v.

Div. of Med. Assistance & Health Servs., 373 N.J. Super. 210,

217 (App. Div. 2004) (quoting Mistrick v. Div. of Med.

Assistance & Health Servs., 154 N.J. 158, 165 (1998)), certif.

denied, 182 N.J. 425 (2005); see also 42 U.S.C.A. § 1396-1.

Although a state is not required to participate, once it has

been accepted into the Medicaid program it must comply with the

federal Medicaid statutes and regulations. See Harris v. McRae,

448 U.S. 297, 301, 100 S. Ct. 2671, 2680, 65 L. Ed. 2d 784, 794

(1980); United Hosps. Med. Ctr. v. State, 349 N.J. Super. 1, 4

(App. Div. 2002); see also 42 U.S.C.A. § 1396a(a)-(b). The

state must adopt "reasonable standards . . . for determining

eligibility for . . . medical assistance [that are] consistent

with the objectives of the Medicaid program[,]" Mistrick, supra,

154 N.J. at 166 (quoting L.M. v. Div. of Med. Assistance &

Health Servs., 140 N.J. 480, 484 (1995)), and "provide for

taking into account only such income and resources as are . . .

available to the applicant." N.M. v. Div. of Med. Assistance &

3 A-1086-14T4 Health Servs., 405 N.J. Super. 353, 359 (App. Div.), certif.

denied, 199 N.J. 517 (2009); see also 42 U.S.C.A. §

1396a(a)(17)(A)-(B).

New Jersey participates in the federal Medicaid program

pursuant to the New Jersey Medical Assistance and Health

Services Act, N.J.S.A. 30:4D-1 to -19.5. Eligibility for

Medicaid in New Jersey is governed by regulations adopted in

accordance with the authority granted by N.J.S.A. 30:4D-7 to the

Commissioner of the Department of Human Services (DHS). DMAHS

is the agency within the DHS that administers the Medicaid

program. N.J.S.A. 30:4D-5, -7; N.J.A.C. 10:49-1.1.

Accordingly, DMAHS is responsible for protecting the interests

of the New Jersey Medicaid Program and its beneficiaries.

N.J.A.C. 10:49-11.1(b). The local county welfare agency (CWA)

evaluates eligibility. N.J.S.A. 30:4D-7a; N.J.A.C. 10:71-1.5, -

2.2(c). Through that agency, DMAHS serves as a "gatekeeper to

prevent individuals from using Medicaid to avoid payment of

their fair share for long-term care." W.T. v. Div. of Med.

Assistance & Health Servs., 391 N.J. Super. 25, 37 (App. Div.

2007).

DMAHS provides institutional level Medicaid benefits to

individuals residing in nursing homes pursuant to the Medicaid

Only program, N.J.A.C. 10:71-1.1 to -9.5. Among other

4 A-1086-14T4 eligibility requirements, an applicant seeking such benefits

must have financial eligibility as determined by the regulations

and procedures. See N.J.A.C. 10:71-1.2(a). In order to be

financially eligible, the applicant must meet both income and

resource standards. N.J.A.C. 10:71-3.15. Generally, an

individual's countable available resources cannot exceed $2000.

N.J.A.C. 10:71-4.5(c), -4.8(a). The resource eligibility

requirements for the Medically Needy Program, of which Arthur

was a beneficiary, are the same as those for the Medicaid Only

program, except the resource limit is $4000 for an individual.

N.J.A.C. 10:70—5.1, -5.3(a).

In the eligibility determination, the CWA considers

all income and resources of the individual . . . and resources which the individual . . . is entitled to but does not receive because of action or inaction by the individual or . . . by any person, including a court or administrative body with the legal authority to act in place of or on behalf of the individual[.]

[N.J.A.C. 10:71-4.10(b)(3) (emphasis added).]

A "resource" is defined as

any real or personal property which is owned by the applicant (or by those persons whose resources are deemed available to him or her as described in N.J.A.C. 10:71-4.6) and which could be converted to cash to be used for his or her support and maintenance. Both liquid and non-liquid resources shall be considered in the determination of

5 A-1086-14T4 eligibility unless . . . [they] are specifically excluded under . . . N.J.A.C. 10:71-4.4(b).

[N.J.A.C. 10:71-4.1(b) (emphasis added).]

See also N.J.A.C. 10:71-4.2. A resource is considered

"available" to an individual when "[t]he person has the right,

authority or power to liquidate real or personal property or his

or her share of it[,]" or when "resources have been deemed

available to the applicant" pursuant to N.J.A.C. 10:71-4.6.

N.J.A.C. 10:71-4.1(c)(1)-(2).

In addition to requiring participating states to adopt

Free access — add to your briefcase to read the full text and ask questions with AI

Related

H.S. v. Ocean County Board of Social Services
New Jersey Superior Court App Division, 2026
R.G. v. Division of Medical Assistance and Health Services
New Jersey Superior Court App Division, 2025
In the Matter of G.W., Etc.
New Jersey Superior Court App Division, 2025
S.P. v. Division of Medical Assistance and Health Services
New Jersey Superior Court App Division, 2025
A.D. v. Essex County Department of Family Services
New Jersey Superior Court App Division, 2025
Estate of Leonor R. Dizon, Etc. v. State of New Jersey, Etc.
New Jersey Superior Court App Division, 2025
M.L. v. Essex County Division of Family Assistance and Benefits
New Jersey Superior Court App Division, 2025
I.M. v. Division of Medical Assistance and Health Services
New Jersey Superior Court App Division, 2025
R.R. v. Division of Medical Assistance and Health Services
New Jersey Superior Court App Division, 2024
In the Matter of Davi H. Kato Special Needs Trust
New Jersey Superior Court App Division, 2024
H.L. v. Division of Medical Assistance and Health Services
New Jersey Superior Court App Division, 2023

Cite This Page — Counsel Stack

Bluebook (online)
153 A.3d 242, 448 N.J. Super. 252, 2017 WL 367992, 2017 N.J. Super. LEXIS 8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-the-estate-of-arthur-e-brown-njsuperctappdiv-2017.